May 20, 2015 

U.S. Department of Transportation Docket Management System 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Exemption Request Pursuant to Section 333 of the FAA Modernization and Reform 

Act of 2012, 49 U.S.C. § 44701 (f), and Part 11 of the Federal Aviation Regulations 

Dear Sir or Madam: 

Remote Intelligence, LLC. ("RI"), pursuant to Section 333 of the FAA Modernization and Reform 

Act of 2012 (the "Reform Act") ("Section 333"), Subsection (f) of 49 U.S.C. § 44701, and 14 

C.F.R. Part 11, is requesting an exemption from the Federal Aviation Regulations ("FARs") 

listed below and discussed in Appendix A to allow Rl to conduct commercial operations with 

Prioria's Maveric small Unmanned Aircraft System ("sUAS") (the "Maveric") and Prioria's 

Hexacopter small Unmanned Aircraft System (the "Hex") to provide surveying and energy 

development services, which are primarily located in remote unpopulated areas with minimal air 

traffic. These services include obtaining still photographs, real-time video, and other data taken 

by onboard sensors to monitor operations, environmental conditions, and forestland security. 

Performing these services with a sUAS is in the public interest for several reasons, which are 

detailed further herein and include: (1) minimizing safety risks inherent in manned operations, 

both in the air and on the ground; (2) inspecting locations where humans are not able to go; (3) 

enhancing capabilities to utilize the sUAS to assist first responders on safety or environmental 

incidents; (4) improving access control/security to sites; and (5) monitoring environmental 

conditions. 

The battery-powered Maveric weighs 2.6 pounds and has a flight time of 40-75 minutes 

depending on operating conditions. It employs a self-stabilizing aircraft configuration with 

stability augmentation avionics that provides ease-of-control and steady video imagery. Its highperformance design leverages advanced composite materials, innovative electronics, and 

cutting-edge sensor technology to increase mission capabilities and make Maveric a reliable 

and accurate solution to meet a variety of industry needs. The Maveric has operated in the 

United States under two Certificate of Waiver or Authorizations ("COAs"). 1 Additionally, the 

Maveric has received operating approvals in Canada and Australia, and has been operated by 

the U.S. Army. 

1 Certificate of Waiver or Authorization 2011-ESA-26, issued to the Department of Energy Oak Ridge National 

Laboratory, and Certificate of Waiver or Authorization 2012-WSA-53, issued to Oregon State University. 

page 1 of 22 
The battery-powered Hex weighs 15.4 pounds with a flight time of 20-25 minutes, depending on 

operating conditions. It also employs stability augmentation avionics to provide ease-of-control 

and steady imagery. It is able to carry a larger payload, up to 5 pounds, giving it a wider range 

of useful sensor options for mapping and monitoring. 

Operations under the exemption will be conducted under the limitations and conditions set forth 

in Appendix Band as may be modified by the FAA as required by Section 333.2 Use of the 

Maveric and Hex in Rl's operations as proposed herein would provide significant public safety 

benefits over existing inspection and survey operations, while operating safely within the 

National Airspace System ("NAS"). 

Use of sUAS offer numerous safety benefits for operations on the ground. First, the use of 

sUAS would alleviate the need for personnel to perform difficult and dangerous manual 

inspections of remote, hazardous, or inaccessible locations along pipelines or facilities. Second, 

sUAS will be able to more quickly and thoroughly assess safety conditions of roads used by 

vehicles following storm events. Third, use of sUAS would increase situational awareness of the 

surroundings and help prevent conflicts if wildlife or unauthorized personnel gain access to the 

property, or if a wildfire or other event threatened the facilities. Finally, the use of sUAS would 

improve visual access to areas that are off limits to foot traffic and machinery due to risk of 

unstable, shifting earth or moving water. 

The use of sUAS would provide Rl's clients with additional data it can use to conduct safer and 

more efficient operations. For inspections now conducted by manned aircraft, use of the sUAS 

for these services will reduce the need to operate manned aircraft in a difficult environment and 

reduce the environmental impact of conventional aircraft operations. In addition, the small, 

lightweight, and easily controllable operating characteristics of the Maveric and Hex provide for 

safe operations over the remote or uninhabited locations of gas development and timberland. 

This feature would also be beneficial in surveying from above in detail features of facilities that it 

would be too dangerous to fly manned aircraft close to. Our clients also maintain strict control 

over access to their facilities, require all personnel to wear personal protective gear, including 

hard hats and safety glasses, and attend site-specific safety hazard briefings to be onsite, so 

these proposed operations would not endanger workers onsite. 

Although the Maveric and Hex can be operated by one person, Rl flight operations will always 

involve at least two people as required by the FAA: a vehicle operator ("VO") and a mission 

operator ("MO"). The VO is responsible for flying the sUAS, monitoring its status and flight 

dynamics, while keeping the flight within the manufacturer's specified operational limits to 

ensure safe operation of the vehicle. MOs will be responsible for monitoring the airspace for 

other aircraft and hazards and advising the VO before and during flight of all such observed 

risks. In addition to completing either Rl training taught by a Prioria-accredited trainer or Prioria 

sUAS operator training, the VO will hold at least a private, sport, or recreational pilot certificate 

and third-class medical certificate or a state-issued motor vehicle Driver's license. 

page 2 of22 
While Rl has modeled its request off of Part 333 Exemption grants as of the date of its 

application, Rl requests that the FAA treat Rl's application as requesting the most lenient relief 

granted to similar applicants at the time of adjudication. Additionally, should the FAA modify any 

of its sUAS operating conditions through exemptions or otherwise after adjudicating Rl's 

application, Rl requests blanket approval to operate its sUAS in accordance with the more 

lenient operating conditions. Rl reserves the right to supplement or amend its application. 

Applicant Information: 

The name of the applicant is: Remote Intelligence, LLC. 

The primary contact for this application is: 

Rob Schwarz 

953 Lake Road 

Wellsboro, PA 16901 

Phone: (570) 244-7960 

Email: rob@remote-intelligence.com 

Exemptions Requested: 

Remote Intelligence requests exemptions from the following regulations: 14 C.F.R. Part 21; 14 

C.F.R. 61.113(a) and (b); 14 C.F.R. 91.7(a); 14 C.F.R. 91.119(c); 14 C.F.R. 91.121; 14 C.F.R. 

91.151(a); 14 C.F.R. 91.405(a); 14 C.F.R. 91.407(a)(1); 14 C.F.R. 91.409(a)(1) and (2); 14 

C.F.R. 91.417(a) and (b). 

Airworthiness of the sUAS: 

The Maveric has been shown to be airworthy and compliant through a history of granted flight 

operations in the United States, Canada, and Australia and successful flights in all three 

countries. The U.S. Military has accepted the Maveric for use as well and has flown it since 

2011 in places like Afghanistan. Globally, the Maveric has amassed over 4,000 flight hours. For 

additional safety, the Maveric is equipped with automated features that ensure safe takeoff, 

flight, and landing in many conditions, further details of which are provided in Appendix C. In 

support of this application, the Maveric Operator's Manual ("Operator's Manual") will be 

provided. All flights will include an extensive pre- and post-flight inspection and systems check, 

following a prescribed protocol. 

The Hex is a more recently developed system, which does not have the extensive history or 

proprietary (Prioria-developed) features of the Maveric. It does, however, utilize industrystandard sensors and controls, which provide numerous failsafes, and have amassed 

thousands of flight hours with modifications in response to observed problems. The Hex is 

equipped with automated features for safe takeoff, flight, and landings in varying conditions. 

The shorter flight times and very high maneuverability will dictate that this system will be used in 

close proximity to the operator and at lower altitudes, which will increase the safety of the 

system. As with the Maveric, a Hex Operator's Manual will be provided. Pre- and post-flight 

page 3 of22 
inspections and systems checks will precede and follow each flight following a prescribed 

protocol. Test flights are conducted following any upgrades to system software, firmware, or 

hardware to ensure safety of operations. 

Operating Conditions: 

Rl requests an exemption subject to the conditions listed in Appendix B, which are substantially 

similar to the operating conditions required for the FAA's previous grants of exemptions under 

Section 333. In accordance with the conditions approved in previous exemption grants, Rl is 

requesting authority to operate the Maveric and Hex within visual line of sight and below 400 

feet AGL except as provided by FAA Air Traffic Control via COA. The area of operations would 

include those lands owned or leased by Rl's clients in the natural gas, wildlife, or timberland 

management industries across the United States. Given that the operating sites are often not 

flat, Rl will use the elevation of the highest predominant terrain within 1 mile of the launch point 

and within the visual line of sight as a ground reference point to establish the 400 feet ceiling. 3 

In other words, Rl will not operate the Maveric or Hex any higher than 400 feet above the 

highest point within 1 mile from the launch point, and will only do so provided the UAS is within 

the line of sight. These operating conditions, along with those listed in Appendix B, would 

provide an equivalent level of safety for the reasons described below. 

First, Rl's clients are generally located in remote areas that rarely see air traffic that they 

are not aware of in advance. 

Second, flight operations in many of our client locations are limited due to the terrain. In 

addition to the requirement that pilots must fly at least 500 feet AGL, the FAA recommends that 

pilots operating under Visual Flight Rules ("VFR") fly over ridges with at least 1 ,000 feet 

clearance. Pilots flying under instrument flight rules ("IFR") over mountainous areas must fly at 

"an altitude of 2,000 feet above the highest obstacle within a horizontal distance of 4 nautical 

miles from the course to be flown." 2 Given the locations of our projects and FAA minimum flight 

altitudes, the Maveric and Hex will be able to operate below altitudes in use by manned aircraft. 

Third, the VO will operate the Maveric and Hex from higher elevations in regard to 

project area when possible, allowing the MO to maintain full visibility of the airspace over the 

project to avoid conflict with any manned aircraft. Rl will use a MO who will stay in radio contact 

with the VO if the terrain warrants it. Additionally, Maveric's nose camera and Hex's forwardfacing camera will provide real-time video of the sUAS's environment that the VO can use to 

avoid any airborne aircraft and other obstacles. 

Fourth, Rl's operational procedures will require VOs to deconflict by suspending all 

sUAS operations when a manned aircraft operates within airspace infringement boundaries, 

2 FAA Aviation Safety Program, Tips on Mountain Flying, available at 

https://www.faa.gov/regulations_policies/handbooks_manuals/aviation/media/tips_on_mountain_flying.pdf. Pilots 

operating under VFR also must operate at an altitude that would allow them to make an "emergency landing without 

undue hazard to persons or property on the surface." 14 C.F.R. § 91.119(a). 6 FAR 91.177(a)(2)(i). 

page 4 of22 
greatly reducing the risk to any manned aircraft. The VO will be able to immediately land the 

sUAS when the VO or MO spot another manned aircraft within the planned area of operations 

or safety personnel direct cessation of sUAS operations. 

Fifth, Rl maintains contact with any personnel onsite, requiring all personnel to wear 

personal protective gear, including hard hats and safety glasses, and mandates site specific 

safety training as required by clients. Non-participant Rl employees will carry radios and be 

alerted before sUAS operations begin. These safeguards, along with the sUAS's light weight, 

provide an equivalent level of safety for non-participants to be closer than 500 feet. 

Sixth, the Maveric and Hex is equipped with visible strobe lights that will alert any 

manned aircraft in the area to its position. 

Seventh, the Maveric's and Hex's flight software provides many built-in functional and 

safety features to assist the VO in safe and reliable operation. Both systems can operate 

autonomously in "Navigation" mode. In Navigation mode, the VO selects waypoints, rally points, 

and a landing area before launching. The sUAS then uses GPS navigation to follow the preselected flight path. The sUAS also can be flown in a semi-autonomous mode in which the 

sUAS flight software maintains a preset altitude and airspeed and the VO controls heading. 

Additionally, the flight software allows the VO to set certain failsafes, i.e. actions the sUAS will 

take in response to loss of link, loss of GPS, and low battery regardless of the flight mode in 

which the sUAS is currently operating. For example, the VO can configure the failsafe so that, in 

a loss of link situation, the sUAS flies to a pre-set waypoint and loiters for a short time to give 

the sUAS time to reconnect with the ground control station and lands at a pre-set landing spot if 

loss of link persists beyond a pre-determined length of time. The VO can do the same for both 

loss of GPS and low battery situations. Finally, any risk presented by possible helicopter 

medical evacuation flights would be mitigated by requiring the VO to terminate sUAS operations 

at the command of safety personnel or the MO. The VO will maintain constant radio contact with 

safety personnel. Rl requests authorization to operate the Maveric and Hex less than 500 feet 

from nonparticipating employees without barriers or structures to protect them, provided they 

wear customary safety gear (e.g. hard hats). An equivalent level of safety is provided because 

the sUAS's weight, materials, and reliability, along with the required operator training and 

operating environment, prevent these systems from posing a serious risk to clients/employees 

wearing personal protective gear. 3 The safety assessment includes consideration of the 

Maveric's mean time between failures ("MTBF")4 -calculated with a large degree of confidence 

from the operation of the Maveric for over 4,000 hours-and its low kinetic energy. 

Operator Requirements: 

3 Based on guidance issued in Exemption No. 11109, Rl and Prioria will submit a safety assessment, under separate 

cover and with a request for confidentiality, to support their request for additional relief regarding the proximity of nonparticipants. 

4 Prioria's MTBF analysis will be submitted under separate cover with a request for confidentiality. 

page 5 of22 
As a condition to the grant of the exemptions, Rl will require that the VO hold a private, sport, or 

recreational pilot certificate and a valid third-class medical certificate or state-issued motor 

vehicle driver's license. The VO will have accumulated and logged a minimum number of flight 

cycles and hours for daytime operations, as required by the FAA. The VO will also be subject to 

the FAA flight review requirements. The VO and all observers will be required to have 

completed a Rl training course taught by a Prioria-accredited trainer, or Prioria's training 

program. Rl respectfully submits that the operator qualifications take into account the operating 

conditions and characteristics of the particular sUAS. 

Public Interest: 

Rl respectfully submits that its use of the sUAS in lieu of manned operations, which are 

currently conducted with conventional fixed wing and rotary aircraft, offers a net safety benefit 

and will achieve an enhanced level of safety, as mandated under Section 333(c) of the Reform 

Act. Approval of this application also will benefit the public interest by allowing better, safer, and 

more cost efficient information gathering for the ecosystem services and energy development 

industries. Conventional aerial survey and inspection operations using manned aircraft involve 

very heavy aerial vehicles that must transit to the operational location and carry significant 

quantities of combustible fuels and a multi-person crew in piloting and observation roles. These 

operations become even more difficult in the energy and forestry industries due to the terrain. 

By contrast, the Maveric weighs 2.6 lbs. and Hex weighs 15.4 lbs., including its payload, uses a 

battery for power, is carried to and from the area of activity, removes the need for airborne pilots 

and observers, and poses less risk to people and infrastructure on the ground, as well as other 

aircraft. Additionally, no national security issue is raised by the grant of the requested 

exemptions due to the sUAS's small size and load-carrying capacity, as well as its operational 

limitations and absence of flammable fuel. All VOs will have been screened by the Department 

of Homeland Security. On the other hand, the use of these systems is likely to enhance national 

security through better and more accurate monitoring of critical national infrastructure. The grant 

of the requested exemption is in the public interest based on the clear direction in Section 333 

and 49 U.S.C. § 44701 (f), 5 the equivalent and enhanced level of safety of the proposed 

operations, the significant public benefit, and cost savings to be realized as a result of the use of 

sUAS for aerial inspection and survey services. Moreover, the FAA has granted similar 

exemptions for sUAS used to conduct high resolution aerial imaging and surveying operations.6 

Accordingly, the applicant respectfully requests that the FAA grant the requested exemption 

without delay. 

5 Under 49 U.S.C. § 44701 (f), the "Administrator may grant an exemption from a requirement of a regulation 

prescribed under subsection (a) or (b) of this section or any of sections 44702-44716 of [Title 49] if the Administrator 

finds the exemption is in the public interest." 

6 See Exemption Nos.11109, 11110,11136,11166,11167,11170,11172. 

page 6 of22 
Privacy Concerns: 

The proposed operations will take place only in largely unpopulated, remote areas that are 

owned or leased, and access controlled by Rl's clients. Access to these areas is generally 

restricted to employees and authorized personnel only. No privacy issues are raised by this 

application. 

Federal Register Summary: 

Pursuant to 14 C.F.R. § 11.81 (f), the following summary is provided for publication in the 

Federal Register, should the FAA determine that publication is needed: 

Docket No.: No. FAA-2015-__ 

Petitioner: Remote Intelligence, LLC 

Section of 14 CFR: Part 21, § 61.113(a) and (b), § 91.7(a), § 91.119(c), § 91.121, § 

91.151 (a), § 91.405(a), § 91.407(a)(1 ), § 91.409(a)(2), § 91.417(a) and (b). 

Description of Relief Sought: Remote Intelligence is seeking an exemption to 

conduct commercial operations using a small unmanned aircraft (55 pounds or less) in 

remote areas of the United States. 

Rl requests that the FAA not request public comment on its application because it would not set 

a precedent and because the relief requested is identical to exemptions granted previously. 14 

C.F.R. § 11.87. 

Sincerely, 

~~ Robert Schwarz 

1 

page 7 of22 
APPENDIX A 

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SHOWINGS UNDER 

APPLICABLE RULES SUBJECT TO EXEMPTION 

Remote Intelligence requests an exemption from the following regulations as well as any 

additional regulations that may technically apply to the operation of the Maveric sUAS: 

14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 

Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements 

for the issuance of airworthiness certificates as required by § 91.203(a)(1 ). Given the size and 

weight of the aircraft, the operating conditions, design safety features, and the proposed 

conditions and limitations, it is unnecessary to go through the certificate of airworthiness 

process under Part 21 Subpart H to achieve or exceed current safety levels. Such an exemption 

meets the requirements of an equivalent level of safety under Part 11 and Section 333. Section 

333 and 49 U.S.C. § 44701 (f) both authorize the FAA to exempt aircraft from the requirement 

for an airworthiness certificate, upon consideration of the size, weight, speed, operational 

capability, and proximity to airports and populated areas of the sUAS involved. 

In this case, an analysis of these criteria demonstrates that the sUAS operated without an 

airworthiness certificate, under the conditions proposed herein, will be at least as safe, or safer, 

than a conventional aircraft (fixed wing or rotorcraft) with an airworthiness certificate. The 

Maveric weighs 2.6 pounds and Hex weighs 15.4 pounds fully loaded. It will not carry a pilot, 

passenger or flammable fuel. These sUASs operate exclusively within a controlled area predisclosed and in compliance with conditions set forth herein. Unlike other civil aircraft, 

operations under this exemption will be tightly controlled and monitored by the VO and 

observer(s), pursuant to the conditions set forth in Appendix B, the Operator's Manual, and local 

public safety requirements. The lack of flammable fuel and the fact that the aircraft is carried to 

the location and not flown there all establish the equivalent level of safety. The sUAS provides 

at least an equivalent level of safety to that of such operations being conducted with 

conventional aircraft that would be orders-of-magnitude larger and would be carrying 

passengers, cargo, and flammable fuel. 

14 C.F.R. §§ 61.113(a) & (b): Commercial Pilot Privileges 

Sections 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional 

aircraft that carries a pilot, passengers, and cargo, the Maveric is remotely controlled with no 

passengers or property of others on board. The area of operation is controlled and restricted, 

and all flights are planned and coordinated in advance as set forth in the Operator's Manual. In 

conjunction with the required training of the VO and observers, the level of safety provided by 

the requirements included in the Operator's Manual exceeds that provided by a single individual 

page 8 of22 
holding a commercial pilot certificate operating a conventional aircraft. The proposed operations 

will achieve at least an equivalent level of safety. 

14 C.F.R. § 91.7(a): Minimum Safe Altitudes 

Section 91.7(a) prohibits an individual from operating a civil aircraft unless it is in an airworthy 

condition. No FAA standard exists for determining an aircraft's airworthiness when an 

airworthiness certificate is not issued. As the FAA has done with previous exemption grants,7 

airworthiness will be ensured and an equivalent level of safety will be achieved by compliance 

with the operating documents prior to every flight. 

14 C.F.R. § 91.119(c): Minimum Safe Altitudes 

Section 91.119 establishes safe altitudes for operation of civil aircraft. Specifically, Section 

91.119(c) limits aircraft flying over areas other than congested areas to an altitude of 500 feet 

above the surface, except over open water or sparsely populated areas. In those cases, the 

aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. 

Because some of the aerial inspection and survey work must be accomplished at altitudes less 

than 500 feet AGL and nonparticipating employees will be working within 500 feet of the sUAS, 

an exemption from Section 91.119(c) is needed. 

The equivalent level of safety will be achieved because Rl's employees and the client's onsite 

employees are required to wear personal protective gear and because the sUAS, given its size, 

weight, speed, and materials, does not pose a serious risk. Also, every flight will be conducted 

over land owned or controlled by Rl's clients. Compared to aerial inspection operations 

conducted with aircraft or rotorcraft weighing far more than 2.6 pounds (for the Maveric or 15.4 

pounds for the Hex) and carrying flammable fuel, any risk associated with these operations will 

be far less than those currently allowed with conventional aircraft operating at or below 500 feet 

AGL. 

14 C.F.R. § 121: Altimeter Setting 

Section 121 requires each person operating an aircraft to maintain cruising altitude by reference 

to an altimeter that is set "to the elevation of the departure airport or an appropriate altimeter 

setting available before departure." As the sUAS may not have a barometric altimeter, but 

instead a GPS altitude read out, an exemption is required. An equivalent level of safety will be 

achieved by the operator, pursuant to the Operator's Manual, confirming the altitude of the 

launch site shown on the GPS altitude indicator before flight. 

7 Exemption Nos. 11156, 11158, 11159. 

page 9 of22 
14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions 

This regulation prohibits an individual from beginning "a flight in an airplane under VFR 

conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly 

to the first point of intended landing and, assuming normal cruising speed- (1) During the day, 

to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes." 

The Maveric batteries provide approximately 40-75 minutes of powered flight. Without an 

exemption from 14 C.F.R. § 91.151, the Maveric's flights would be limited to approximately 10 

minutes in length because the VO would require the last 30 minutes to satisfy section 91.151 (a). 

The Hex batteries provide approximately 20-25 minutes of flight. Without and exemption from 

14 C.F.R. § 91.151, the Hex's flights would not be allowed to takeoff because the VO would 

require the last 30 minutes to satisfy section 91.151 (a). Given the limitations on its proposed 

operations, a longer time frame for flight in VFR conditions is reasonable. 

Rl believes that an exemption from 14 C.F.R. § 91.151 (a) provides an equivalent level of safety 

and is consistent with prior exemptions. 8 Operating the sUAS, without 30 minutes of reserve fuel 

does not engender the type of risks that Section 91.151 (a) was meant to prevent given the size 

and speed at which the sUAS operates. In the unlikely event that the sUAS' battery runs low, it 

would simply follow the pre-programmed command to land at a designated location. Given its 

weight and construction material, the risks are less than contemplated by the current regulation. 

Rl believes that an equivalent or enhanced level of safety can be achieved by maintaining 10 

minutes of reserve power for the Maveric which, allowing at least 30 minutes of flight time, if not 

more, would be more than adequate to return the sUAS to its planned landing zone from 

anywhere in its limited operating area. For the Hex, because of its shorter flight times and closer 

proximity of flights, Rl believes that 5 minutes of reserve power should be retained, allowing for 

at least 15 minutes of flight time. 

14 C.F.R. §§ 91.405(a), 91.407(a)(1 ), 91.409(a)(2), and 91.417(a): Maintenance Inspections 

Section 91.405(a) requires that an aircraft operator or owner "shall have that aircraft inspected 

as prescribed in subpart E of this part and shall between required inspections, except as 

provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of 

this chapter." Section 91.407 similarly makes reference to requirements in Part 43. Section 

91.409(a)(2) requires an annual inspection for the issuance of an airworthiness certificate. 

Section 91.417(a) requires the owner or operator to keep records showing certain maintenance 

work that has been accomplished by certificated mechanics, under Part 43, or licensed pilots 

and records of approval of the aircraft for return to service. 

Pre-flight checks will be performed by a qualified person prior to each flight and at predefined 

intervals as part of the maintenance schedule. 

8 Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with 91.151 (a)); see also 

Exemptions 2689F, 57 45, 1 0673 and 1 0808 

page 10 of22 
The pre-flight checklist includes: 

1. Visual inspection of the airframe; 

2. Visual inspections of propeller(s); 

3. Verify GPS acquisition; 

4. Plan and upload mission; 

5. Video and payload check; 

6. Controls check; 

7. Gyro/control surfaces check (Maveric only); 

8. Throttle check; 

9. Check pitot tube readings (Maveric only); 

10. Check sensors; and 

11. Verify failsafes are set correctly. 

An equivalent level of safety will be achieved because the sUAS will operate only in restricted 

predetermined areas, and at low altitudes. In addition, the operator will ensure that the sUAS is 

in working order prior to initiating flight, perform required maintenance, and keep a log of any 

maintenance that is performed. Test flights will be conducted prior to operations following 

adjustments to sUAS hardware, software, or firmware. Moreover, the operator is the person 

most familiar with the aircraft and is best suited to maintain the aircraft in an airworthy condition 

and to ensure an equivalent level of safety. Last, the Operator's Manual will have instructions to 

develop and document maintenance, overhaul, replacement, and inspection requirements in the 

absence of Prioria requirements, and procedures to document and maintain maintenance 

records for the sUAS. The sUAS maintenance guidelines provide an equivalent level of safety to 

the maintenance requirements in Part 91. 

page 11 of22 
APPENDIX B 

Rl OPERATING LIMITATIONS 

1) Operations authorized by the grant of exemption are limited to the following aircraft: Prioria's 

Maveric and Hex, which each weighing less than 7 kg. 

2) The sUAS shall not be flown at a ground speed exceeding 60 kts. 

3) The sUAS will not be operated at an altitude more than 400 feet above the highest 

predominant terrain except as may be provided by FAA Air Traffic Control ("ATC") via GOA. The 

highest predominant terrain is defined as terrain within 1 mile of the launch point and within the 

visual line of sight of the VO. All altitudes reported to ATC shall be in feet AGL. 

4) All operations must use a MO. The MO and VO must be able to communicate verbally at all 

times. The VO must be designated before the flight. The VO must ensure that the MO can 

perform the functions prescribed in the operating documents. 

5) The operating documents and this grant of exemption must be accessible during UAS 

operations and made available to the Administrator upon request. If a conflict exists between 

the conditions and limitations in the exemption and the procedures outlined in the operating 

documents, the conditions and limitations in the exemption take precedence and must be 

followed. Otherwise, Rl must follow the procedures as outlined in its operating documents. Rl 

may update or revise its operating documents. It is Rl's responsibility to track such revisions and 

present updated and revised documents to the Administrator upon request. Rl must also 

present updated and revised documents if it petitions for extension or amendment to this grant 

of exemption. 

6) Prior to each flight the VO must inspect the sUAS to ensure that it is in a condition for safe 

flight. The VO shall not operate the aircraft if the inspection reveals a condition that affects the 

safe operation of the sUAS until the necessary maintenance has been performed and the sUAS 

is found to be in a condition for safe flight. The Ground Control Station, if utilized, must be 

included in the preflight inspection. All maintenance and alterations must be properly 

documented in the aircraft records. 

7) Any sUAS that has undergone maintenance or alterations that affect the sUAS operation or 

flight characteristics (e.g., replacement of a flight critical component) must undergo a functional 

test flight in accordance with the Operator's Manual. The VO who conducts the functional test 

flight must make an entry in the aircraft records of the flight. The requirements and procedures 

for a functional test flight and aircraft record entry shall be included in the Operator's Manual. 

8) The pre-flight inspection must account for all discrepancies, e.g. inoperable components, 

items, or equipment, not already covered in the relevant sections of the operating documents. 

page 12 of 22 
9) Rl must follow Prioria's aircraft/component, maintenance, overhaul, replacement, inspection, 

and life limit requirements. 

1 0) Rl must carry out its maintenance, inspections, and record keeping requirements, in 

accordance with the operating documents. Maintenance, inspection, alterations, and status of 

replacement/overhaul component parts must be noted in the aircraft records, including total time 

in service, description of work accomplished, and the signature of the person authorized to 

return the sUAS to service. 

11) Each sUAS operated under this exemption must comply with all manufacturer Safety 

Bulletins. 

12) The VO must possess at least a private, sport, or recreational pilot certificate and at least a 

current third class medical certificate or a valid state-issued motor vehicle driver's license. The 

VO must also meet the flight review requirements specified in 14 C.F.R. § 61.56 in an aircraft in 

which the VO is rated on his or her pilot certificate. 

13) Rl may not permit any VO to operate unless the VO meets the operator's qualification 

criteria and demonstrates the ability to safely operate the sUAS in a manner consistent with how 

the sUAS will be operated under this exemption, including evasive and emergency maneuvers 

and maintaining appropriate distances from persons, vessels, vehicles and structures. 9 VO 

qualification flight hours and currency must be logged in a manner consistent with 14 C.F.R. § 

61.51 (b). The VO must ensure that the MO is trained appropriately in order to fulfill his or her 

duties. A record of training and qualification must be documented and made available upon 

request by the Administrator. Flights for the purposes of training the operator's VOs and MOs 

(training, proficiency, and experience-building), are permitted under the terms of this exemption. 

However, training operations may only be conducted during dedicated training sessions. During 

training, proficiency, and experience-building flights, all persons not essential for flight 

operations are considered nonparticipants, and the VO must operate the UAS with appropriate 

distance from nonparticipants in accordance with these operating conditions. 

14) Operations may not be conducted during night, as defined in 14 C.F.R. § 1.1. All operations 

must be conducted under visual meteorological conditions ("VMC"). Flights under special visual 

flight rules ("SVFR") are not authorized. 

15) The sUAS may not operate within 5 nautical miles of an airport reference point as denoted 

on a current FAA-published aeronautical chart unless a letter of agreement with that airport's 

management is obtained, and the operation is conducted in accordance with a NOT AM as 

required by Rl's COA. The letter of agreement with the airport management must be made 

available to the Administrator upon request. 

9 Prior documented flight experience that was obtained in compliance with applicable regulations may satisfy this 

requirement. 

page 13 of 22 
16) The sUAS may not be operated less than 500 feet below or less than 2,000 feet horizontally 

from a cloud or when visibility is less than 3 statute miles from the VO. 

17) If the sUAS loses communications or loses its GPS signal, the sUAS must return to a predetermined location within the security perimeter and land or be recovered in accordance with 

the Operator's Manual. 

18) The VO must abort the flight in the event of unpredicted obstacles or emergencies in 

accordance with the Operator's Manual. 

19) sUAS operations must be completed within 30 minutes flight time. 

20) Rl must obtain an ATC-issued COA prior to conducting any operations under this exemption 

(unless operations are conducted within the limits of a blanket COA). 

21) All aircraft operated in accordance with the requested exemption must be identified by serial 

number, registered in accordance with 14 C.F.R. Part 47, and have identification (N-Number) 

markings in accordance with 14 C.F.R. Part 45, Subpart C. Markings shall be as large as 

practicable. 

22) The radio frequency spectrum used for operation and control of the sUAS must comply with 

Federal Communication (FCC) or other appropriate government oversight agency requirements. 

23) The documents required under 14 C.F.R. §§ 91.9 and 91.203 must be available to the VO at 

the Ground Control Station of the sUAS any time the aircraft is operating. These documents 

shall be made available to the Administrator or any law enforcement official upon request. 

24) The sUAS must remain clear and yield the right of way to all other manned operations and 

activities at all times. 

25) The sUAS may not be operated from any moving device or vehicle. 

26) The sUAS may not be operated over congested or densely populated areas. 

27) Flight operations must be conducted at least 500 feet from all nonparticipating persons, 

vessels, vehicles, structures, and public access roads unless: 

a. The nonparticipating persons are authorized to access the client's site and are 

wearing personal protective gear; 

b. For non-participants who do not qualify as client employees, barriers or structures are 

present that sufficiently protect them from the sUAS and/or debris in the event of an 

accident. The operator must ensure that nonparticipating persons who are not client 

employees remain under such protection. If a situation arises where nonparticipating 

persons who are not client employees leave such protection and are within 500 feet of 

the sUAS, flight operations must cease immediately; or 

page 14 of22 
c. The aircraft is operated near vessels, vehicles or structures where the 

owner/controller of such vessels, vehicles or structures has granted permission and the 

VO has made a safety assessment of the risk of operating closer to those objects and 

determined that it does not present an undue hazard. 

28) Operations nearer than 500 feet to the VO, MO, operator trainees or essential persons as 

defined in the operating documents are permitted if those operations do not present an undue 

hazard to those persons per§ 91.119(a) as determined by the VO. 

29) All operations must be conducted over remote, private, or controlled-access property. 

30) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries 

of the operational area as defined by the applicable COA shall be reported to the FAA's UAS 

Integration Office (AFS-80) within 24 hours. Accidents must be reported to the National 

Transportation Safety Board (NTSB) per instructions contained on the NTSB Web site: 

www.ntsb.gov. 

page 15 of 22 
APPENDIX C 

SMALL UNMANNED AERIAL SYSTEM DESCRIPTION 

Remote Intelligence Corporate Overview: 

Remote Intelligence is a Pennsylvania corporation with its headquarters in Wellsboro, 

Pennsylvania. Rl is a premier U.S.-based natural resource and ecosystem service company 

with industry-leading experience, significant oil and gas collaborations, and a growing emphasis 

on educational partnerships. 

Maveric sUAS SYSTEM DESCRIPTION 

sUAS Operating Overview - Maveric: 

The Maveric is a fixed-wing aircraft constructed of a rugged carbon fiber composite with 

bendable wings that requires no assembly. It has fully autonomous operation for takeoff, 

navigation, and landing. 

Parameter 

Wingspan 

Length 

Weight, with EO side-look payload 

Wireless Range 

Cruise Speed (Best Endurance) 

Dash Speed 

Stall Speed 

Max wind 

Characteristic 

29.5 in 

26.5 in 

2.61bs 

5-15 km LOS 

26 kts (30 mph) 

55 kts (63 mph) 

18 kts (21 mph) 

20 kts sustained, 30 kts gusting 

page 16 of 22 
Precipitation 

Flight Duration 

Turn Rate 

Climb Rate 

Launch 

Landing 

Flight Control 

Exterior Lighting 

Command and Control Frequency 

Video Bands 

Light rain (0.1 inches per hour) 

45- 70 minutes 

360 degrees in 12 seconds 

500ft/min @ 2,000 AMSL 

Hand launch, tube launch optional 

Deep-stall, skid, net optional 

Autonomous or manual 

Visible and IR Strobe Lights 

350 MHz, 900 MHz 

1.7 GHz, 2.4 GHz 

The sUAS can be operated in fully autonomous flight modes. Creating pre-planned flight paths 

to fly in autonomous mode is as simple as clicking on the map to create a pre-planned flight 

path. Pre-mission waypoints, landing zone points, and flight area dimensions can all be entered 

during preflight, ensuring the sUAS operates only within specified parameters. 

The Maveric includes many advanced safety features that makes it the safest choice for areas 

like pipeline construction. Built-in intelligent fault handling allows the sUAS to detect a system 

fault while in the air, and to automatically respond with a set command (one such option being 

to fly back to a preselected rally point and land). Faults that can be detected include: loss of 

communication, loss of GPS, and low battery levels. In addition, the operator can create no fly 

zones, and the system will visually and audibly warn the operator if the planned flight path would 

enter the no fly zone. 

Operator's Manual -The Maveric Operator's Manual will be provided under separate cover 

with a request for confidential treatment. 

Power- The Maveric and its ground control station are both powered by a Lithium polymer 

rechargeable battery pack. A new battery has a fully charged voltage of approximately 12.4V. A 

"full-pack" has a capacity of 4 Amp-hours. An additional "half-pack" can be installed for 

extended operation. A new "half-pack" has a fully charged voltage of 12.4V and a capacity of 2 

Amp-hours. The Maveric's battery charge is displayed in real-time on the ground control 

terminal, ensuring maximum flight duration and safety. 

Takeoff and Landing style/type- The Maveric is hand launched and can be tube launched 

with additional equipment. The Maveric lands by returning to a pre-determined rally point and 

beginning a spiral descent. Once it reaches a preselected altitude, it heads toward the landing 

waypoint, descending until it lands and skids to a stop. 

Navigation System -Specific maps can be downloaded to the display screen (such as air 

sectional and geographic maps) which are overlaid with GPS positional data. Waypoints can be 

created before and during flight operation creating specific locations and sequences for the 

aircraft. 

page 17 of 22 
Defined "Keep Out" Areas- The navigation software allows for preplanning Keep Out Areas 

that allow the operator to designate airspace he or she does not want the Maveric to enter. If 

defined flight paths pass through an area designated as keep-out, the individual waypoints and 

waypoint connection segments turn red as a warning. Additionally, if a mission is uploaded and 

intersects with a keep out area, a warning is presented to the user. Also, if an aircraft in flight is 

navigated into a designated keep out area, an audible warning is sounded. 

Maintenance- The Maveric sUAS needs very little maintenance, and operators may perform 

most required maintenance in the field with the field repair kit. 

Command and Control Systems -The sUAS Ground Control Station (GCS) allows the 

operator simultaneous control over aircraft and payloads. The display screen provides all 

essential flight data to the operator. Telemetry data is transmitted to the command station at 

least once per second. 

Displayed on GCS: 

• Current position 

• Registered home position 

• Any autopilot flight plans 

• Registered emergency landing zone 

• Aircraft attitude 

• Altitude 

• Airspeed 

• Groundspeed 

• Compass reading/heading 

• Estimated wind heading 

• Communication strength 

• Range from home 

• Bearing from home 

• Duration of current mission 

• Rate of climb 

• Mode of the aircraft 

• Battery level 

Emergency Procedures and System Failures 

Loss of Link- The sUAS does not need constant signal from the GCS to continue flying. 

Communications outages are detected by the system and are reported to the VO. During the 

communication outage, the sUAS continues on its pre-determined flight path until a failsafe is 

triggered. Once a failsafe is triggered, the sUAS will perform in accordance with the failsafe 

conditions uploaded before launch. This is accomplished without input from the operator. 

Security 

The system and communication links may be encrypted. 

page 18 of22 
HEX sUAS SYSTEM DESCRIPTION 

sUAS Operating Overview: Prioria's Hex Flyer is a multi-rotor, vertical take-off and landing 

platform. It simplifies users' installation and enables quick disassembling. Frame arm integrates 

with ESC and motor. With DJI WKM autopilot system, it can achieve hovering, cruising and 

other flight elements. Hex Flyer can be applied for aerial photography and other aero-modeling 

activities. 

The basic airframe T81 0 is manufactured by Tarot-RC, leading manufacturer of consumer and 

commercial grade unmanned aerial systems. The T81 0 airframe is used extensively in TV and 

film industry as an aerial video/photo platform. Prioria performs all assembly and payload 

integration. 

Parameter ; I : CharacterisJlc ; ::; ,': 

; 

Wingspan (rotor tip to rotor tip) 37in 

Height 12.6 in 

Weight, with standard payload 15.4 lb 

Wireless Range <5 km LOS 

Rate of Climb 6 m/s max 

Rate of Descent 3 m/s typical 

Cruise Speed 10 m/s 

Approach Speeds N/A 

Operating Altitude Range 175 m (limited by SW) 

Max wind 15 kts sustained, 20 kts gusting 

Precipitation None 

page 19 of 22 
Flight Duration 15-25 Minutes 

Turn Rate 360 degrees in 12 seconds 

Climb Rate 500 ftlmin @ 2,000 MSL 

Launch Vertical takeoff 

Landing Vertical landing 

Flight Control Autonomous or manual 

Exterior Lighting Yes 

Command and Control Frequency 900Mhz I 2.4 Ghz 

Video Bands 1.2 or 5.8 Ghz 

Operational Characteristics 

Characteristic Yes/No 

Lights Out Operation No 

VFR Operations Yes 

IFR Operations No 

Day Operations Yes 

Night Operations No 

Avionics Equipment 

Equipment Yes/No 

GPS Yes 

Moving Map Indicator Yes 

Tracking Capability No 

TCA/MCAS Collision Avoidance No 

EL T (Falcon Tracker) Yes 

Transponder No 

The sUAS can be operated in fully autonomous flight modes. Creating pre-planned flight paths 

to fly in autonomous mode is as simple as clicking on the map to create a pre-planned flight 

path. Pre-mission waypoints, landing zone points, and flight area dimensions can all be entered 

during preflight, ensuring the sUAS operates only within specified parameters. 

Built-in intelligent fault handling allows the sUAS to detect a system fault while in the air, and to 

automatically respond with a set command (one such option being to fly back to a pre-selected 

rally point and land). Faults that can be detected include: loss of communication, loss of GPS, 

and low battery levels. 

page 20 of22 
Operating ManualPower - The Hex and its ground control station are both powered by a Lithium polymer 

rechargeable battery pack. A new battery has a fully charged voltage of approximately 25.1 V. 

The Hex's battery charge is displayed in real-time on the ground control station, ensuring 

maximum flight duration and safety. 

Launch and Recovery Procedures 

The Hex Flyer utilizes vertical takeoff and landing, commanded either via Radio Control 

Transmitter or Automatic operation via Data Link and Ground Station Software. 

In RC mode, Pilot uses GPS, Attitude, or Manual modes via RC hand controller to maneuver 

aircraft for takeoff or landing. 

To utilize automatic operation, Pilot sets GPS flight mode in RC Controller, then uploads flight 

plan to aircraft via Datalink. Once upload is complete, pressing "GO" button in GS activates auto 

takeoff and flight to first waypoint in flight plan. For landing, pilot sets Go Home mode in GS. 

Once Aircraft is situated over Home waypoint in stable hover, Pilot sets "Autoland" mode. 

Aircraft then executes slow descent automatic landing. 

Takeoff and Landing style/type- The Hex uses a vertical takeoff and landing style, 

commanded either via Radio Control Transmitter or Automatic operation via Data Link and 

Ground Station Software. R/C: Pilot uses GPS, Attitude, or Manual modes via RC hand 

controller to maneuver aircraft for takeoff or landing. 

Automatic: Pilot sets GPS flight mode in RC Controller, then uploads flight plan to aircraft via 

datalink. Once upload is complete, pressing "GO" button in GS activates auto takeoff and flight 

to first waypoint in flight plan. For landing, pilot sets Go Home mode in GS. Once Aircraft is 

situated over Home waypoint in stable hover, Pilot sets "Autoland" mode. Aircraft then executes 

slow descent automatic landing. 

Navigation System -GCS uses Google Earth Plugin for live map imagery which can also be 

pre-cached for offline use in the field. Waypoints can be created before and during flight 

operation creating specific locations and sequences for the aircraft. 

Maintenance - The Hex sUAS needs very little maintenance, and operators may perform most 

required maintenance in the field with the field repair kit 

Command and Control Systems- The Main Controller (MC) is the brain of the system. It 

communicates with the IMU, GPS/Compass, ESCs, and RC transmitter to carry out autopilot 

functionality. The Main Controller has a USB interface for configuration and firmware updates 

via a PC. The Inertial Measurement Unit (IMU) consists of one 3-axis accelerometer, one 3-axis 

gyroscope and a barometer. It is used for sensing the attitude. The GPS/Compass module is for 

sensing the position and direction. The LED indicates different states of system. Specially 

designed for the Controller to convert the higher voltage of the power circuit to the lower voltage 

page 21 of 22 
required for the receiver etc. It contains two regulated power outputs for the entire Controller 

system and receiver separately, a battery voltage monitor, and CAN-Bus interfaces. 

Ground Control Station 

Ground Station enables 3-D Map Way Points Editing, Flight Path Planning, Real-time Flight 

State Feedback and Auto Takeoff and Landing. Working with the autopilot system, DJI Ground 

Station not only ensures stable performance and safety of the aircraft, easy operation for the 

pilot, but also allows the aircraft to fly along the flight path set before or modified during the flight 

mission in the Ground Station software autonomously. 

Displayed on GCS: 

• Current position 

• Home position 

• Flight plan 

• Aircraft attitude 

• Altitude 

• Airspeed 

• Groundspeed 

• Compass reading/heading 

• Communication strength 

• Range from home 

• Bearing from home 

• Duration of current mission 

• Rate of climb 

• Mode of the aircraft 

• Battery level 

Emergency Procedures and System Failures 

Loss of Link- The sUAS does not need constant signal from the GCS to continue flying. 

Communications outages are detected by the system and are reported to the PIC. 

During the communication outage, the sUAS continues on its pre-determined flight path 

until a failsafe is triggered. Once a failsafe is triggered, the sUAS will perform in 

accordance with the failsafe conditions uploaded before launch. This is accomplished 

without input from the operator. 

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